ROCKINGHAMCOUNTY 113 North Road Brentwood.NH 03833-6623 (603) 679-561 6 Fax (603) 679-8070 extension.unh.edu county Offices Belknap County 527-5475 Carroll County 539-3331 C061 County 788-4961 Grafton County 787-6944 Hillsborough County 641-6060 Rockinghamcounty 679~5616 Straffard County 749-4445 Suliivan County 863-9200 Famiiy,Hame&Garden Education Center 629-9494 (Office1 877-398-4769 (Toll Free) UNH Cooperative Extension State Office 862-1520 February 6,2009 Easements Programs Division Wetlands Reserve Program Conu~lcnts, P.O. 2890 Room 68194 Washington, DC 20013 Docket # NRCS-IFR-08013 Dear Sirs: UNIVERSITY of NEW HAMPSHIRE COOPERATIVE EXTENSION i RECEIVED FEB 1.0 My work involvcs helping private landowners, conservation organizations, comnlnnities and other groups conservc land. As such I have a great deal of contact and interaction with agcncies such as NRCS and the various federal programs thcy administer that provide funding for land conservation including WRP and FRPP. This note is inrcsponse to thc opportunity to provide written comment to the WRP Rulcs. e Template Conservation Easen~cnt - To date the program has functioned with a "one size fits all" conswvation easement coupled with stand alonc Compatible Use Agreements between the landowner and NRCS. This is a troublesome arrangement at best and no doubt will present legal challenges that may well threaten the long term viability of easements con~pleted under WRP. I urge NRCS to allow cach rcgion or, better yet, each state to dcvclop template WRP conservation easements writtenby a tcam madc up of NRCS staff, Statc Tcchical Committees and private conservation organizations. WRP tcnlplate easements should incorporate all Compatible Uses that will be allowed by each NRCS Statc Director. Modifications to the template can be made to reflect property uniqueness and landowner interests. 7 Year Ownership Rcquircmcnt - This ncw mle will reduce enrollment in WRP radically in New Hampshire and many other states. Many of the Iandowncrs wc dcal with have recently inherited or purchascd thcir propcrty. This is because we are in a rapidly growmg reglon and because of thc long prcdictcd gcncrational transfer due to our aging landowner basc. I would urgc you to restore this and all programs to thc formcr rulc which rcquired ownership to be at least onc ycar. 0 Town Propcrty Exclusion - The new rule excludes towns and cities from enrolling in WRP and numerous othcr USDA programs. This rule change will negatively impact cnrollnlcnt in much of Ncw England and will exclude an exciting and rapidly growing scgmcnt of landownership. In virtually cvcry New England state, communities have taken great steps to idcntify and ultinlately purchasc kcy parccls with significant natural resource features. New Hampshire communities alone havc invcstcd $143 n~illion over the last 7 years in conserving land. Much of this invcstnlent has been in fee acquisitions. Usc of WRP funding to pcrn~anently conserve community owned properties provides long tern conservation and helps leveragc funding derived by resident taxpayers. SinccreIy, Phil A u m